Comment on DOD_FRDOC_0001-DRAFT-0065

I am commenting on the Department of Defense Proposed Rule for the revision of DoD 1322.25, Voluntary Education Programs on the Federal Register. Firstly it is excellent that the DoD appreciates the value of partnering with accrediting groups by adding the requirement that an institution must be accredited by an accrediting agency recognized by the US Secretary of Education. This makes good fiscal sense, and the depth and rigor of a DETC accrediting review will serve the DoD well. My one concern is #5 the requirement of an MVER visit. This could cause undue hardship, particularly to smaller colleges. I would suggest a modification of either a DoD individual joining the accreditation site visit teams or of the DoD accepting the depth and rigor of the accrediting site visit. This could apply where there is a long history of compliance with the funding program's requirements - ie submitting grades on time, degree plans, course information as requested and other applicable compliance requirements. It would also be ideal if this was only required when an institution received a certain volume such as XX dollars or XX% of total revenue from Vol Ed funding programs.